Mannex Corp. v. Bruns

To claim the tort of intentional interference of economic relations the plaintiff must show that the defendant is a third party to the contract. Communications made by an employee to protect the interests of their employer are qualifiedly privileged.

Mannex Corp. (Mannex) appealed trial court’s decision granting summary judgment to Bruns. Mannex brought an action against Bruns for intentional interference with economic relations (IIER) and defamation. Bruns was a purchasing manager at PCC Structurals Inc. (PCC). Bruns compiled a report of indiscretions made by Mannex during their business interactions and told other employees and the employer of her distrust of Mannex. These actions, along with subsequent policy infractions by Mannex, led to the complete termination of Mannex as a vendor for PCC. The trial court held that the plaintiff did not introduce enough evidence demonstrating Bruns was a third party and that her actions were the cause of legal injury. The Court of Appeals found that with respect to the IIER there was no evidence Bruns was a third party. For the defamation claim, there was evidence that Mannex was terminated as a vendor because of Bruns’ reports and statements and that there was legal injury. However, because her statements were made to protect the interests of her employer, the statements were qualifiedly privileged. Therefore, summary judgment on the defamation claim was appropriate. Affirmed.